Compliance
PG&E’s commitment to the environment begins with our adherence to the letter and spirit of the applicable environmental laws and regulations. Our environmental policy and governance practices are designed to promote compliance with environmental requirements and provide the foundation for us to take our performance beyond legal and regulatory baselines.
Our Approach
Environmental Management System
PG&E’s operations are subject to extensive federal, state and local environmental laws and regulations. These requirements relate to a broad range of activities, including preventing the discharge of pollutants; safely transporting, handling and storing hazardous materials; properly managing hazardous wastes; protecting threatened and endangered species; and reporting and reducing carbon dioxide and other greenhouse gas (GHG) emissions.
To ensure we meet these requirements, PG&E uses an Environmental Management System (EMS) modeled after the ISO 14001 environmental management standard and consistent with its “Plan, Do, Check, Act” model for continuous improvement. The system uses a series of compliance work processes that enable PG&E to manage regulatory compliance and our environmental impacts by each line of business.
The Vice President of Safety, Health and Environment for Pacific Gas and Electric Company oversees our commitment to meet safety and environmental requirements. PG&E’s integrated planning process provides a mechanism for managing environmental risk and compliance while driving continuous improvement, as do enterprise-wide initiatives such as the Corrective Action Program and numerous other forums.
Compliance performance updates are reviewed monthly by PG&E’s officers, and an annual environmental compliance summary is presented to the Compliance and Public Policy Committee of the PG&E Corporation Board of Directors.
2015 Milestones
Planning
Our current system uses a series of work processes to manage regulatory and environmental performance by each line of business. We monitored the changes to the ISO 14001:2015 standard to inform and improve these processes.
Implementation and Operation
PG&E employs a variety of operational controls to help ensure that the actions we take in meeting our environmental compliance obligations are correct and repeatable. We also learn from those experiences and integrate any lessons into our work processes and staff development.
In 2015, we continued to find new opportunities for applying technologies and processes to further our compliance efforts and minimize impacts on the environment. Key EMS initiatives included:
- The development of an SAP-based compliance tool that can analyze trends and inform our risk management efforts.
- Expanding the use of an automated tool that uses Geographic Information System spatial data to assess projects for potential environmental impacts.
- Leveraging enterprise-wide initiatives such as records and information management and the integrated planning process to embed environmental risk assessments into long-term planning.
PG&E conducts extensive training to ensure employees have the skills and knowledge to correctly perform environmental activities associated with their work. Each year, PG&E trains thousands of employees on various environmental compliance responsibilities. Additionally, we require all employees to take a training course on our environmental policy to reinforce every employee’s role in supporting PG&E’s goal of environmental leadership.
Reviews and Corrective Actions
A robust environmental auditing program is critical to ensure compliance with the many environmental laws and regulations relating to our business.
We review and audit environmental performance in four ways: self-assessments, comprehensive reviews, compliance and risk management reviews, and internal audits.
- Self-Assessments: Environmental personnel perform self-assessments of facilities or projects they oversee. Each assessment evaluates a facility or project for compliance with environmental regulations.
- Comprehensive Reviews: These reviews are performed by personnel from the Safety, Health and Environment department who are not responsible for compliance at the facility or the project being inspected. Each comprehensive review involves evaluating all environmental compliance obligations associated with the operation of a facility or project.
- Compliance and Risk Management Reviews: These reviews, designed to assess adequacy of controls and risk mitigation, as well as compliance work processes, are conducted by the Compliance and Risk Management team, independent from the Safety, Health and Environment department.
- Internal Audits: The Internal Audit department, which reports directly to the PG&E Corporation Chief Financial Officer, conducts systemic and programmatic controls-based audits to independently analyze the effectiveness of our environmental compliance management systems. The results of these audits are reported annually to the Audit Committees of the PG&E Corporation and Pacific Gas and Electric Company Boards of Directors.
During 2015, we performed 5,540 self-assessments, 58 comprehensive reviews, four internal audits and five compliance and risk management reviews of various environmental processes, facilities and projects.
To drive continuous improvement, we employ a rigorous corrective action process, which includes performing root cause analyses of noncompliance issues identified through environmental agency inspections and tracking detailed corrective action plans to resolution.
Measuring Progress
Operational Performance
PG&E tracks and reports a wide range of annual environmental compliance performance indicators. This section covers our performance results for 2015.
Reported Unintentional Releases and Permit Exceedances
We report unintentional releases that meet regulatory thresholds, as well as many smaller releases, in an effort to ensure operational transparency to local agencies. We reported a total of 170 releases, defined as an unintentional discharge of a regulated substance that exceeds a reporting threshold or thresholds allowed in applicable permits.
Agency Inspections
In 2015, a total of 641 agency inspections were conducted at our facilities. The majority of these inspections were performed by Certified Unified Program Agencies, such as city and county environmental health departments and fire departments.
Environmental Sanctions and Penalties
To measure compliance results, we categorize all written enforcement actions issued by a regulatory agency as Level 1 (findings that resulted in an actual or potential environmental impact) or Level 2 (findings that did not result in an actual or potential environmental impact). We also track the percentage of agency inspections that do not result in written enforcement actions.
We received three Level 1 enforcement actions in 2015. Our rate of inspections without a written sanction was 91 percent, 1 point above our target of 90 percent.
PG&E paid a total of $188,445 in penalties.
| 2013 | 2014 | 2015 | |
|---|---|---|---|
| Level 1 Enforcement Actions | 6 | 5 | 3 |
| Percentage of Inspections Without a Written Enforcement Action | 90% | 93% | 91% |
| Releases/Exceedances | 218 | 134 | 170 |
| Penalties Paid | $64,244 | $3,100 | $188,445 |
| Agency Inspections | 341 | 571 | 641 |
| Audits Performed | 33 Footnote 1 | 44 Footnote 2 | 67 Footnote 2 |
| Self-Assessments Performed | 2,508 | 5,633 | 5,540 |
- 1. Includes system audits and comprehensive reviews. Return to table
- 2. Includes system audits, comprehensive reviews and compliance and risk management reviews. Return to table
Looking Ahead
We will maintain our commitment to continuous improvement as we work to enhance our EMS. In 2016, we will continue to focus on expanding the use of technology to minimize environmental impacts as we perform gas and electric infrastructure improvements. We are also leveraging our enterprise-wide strategic planning process to adopt shared goals and enhancing our EMS to better measure our progress in achieving these goals.
In addition, in 2016 we will perform an independent third-party gap analysis of PG&E’s EMS that is consistent with the ISO 14001 standard.